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Sajithabai and Ors. Etc. v. The Kerala Water Authority and Ors. Etc.

Civil Appeal · 2025 INSC 354Decided 18 Mar 2025
Civil Appeal Nos. 1420-1422 of 2025 (arising from SLP(C) Nos. 12873-12875 of 2024)
Justice Dipankar Datta · Justice Manmohan

Background

Six employees of the Kerala Water Authority, who held engineering degrees but were promoted from Draftsman to Assistant Engineer under the "diploma quota," later sought to switch to the "degree quota" for further promotion to Assistant Executive Engineer. Two directly-recruited Assistant Engineers challenged the seniority list that resulted, and a Single Judge of the Kerala High Court, upheld by a Division Bench, ruled that the six could not make this switch, since they had originally been promoted under the diploma stream.

Decision Breakdown

The Supreme Court allowed the appeals, holding that the special promotion rules governing Assistant Executive Engineers give every serving Assistant Engineer, regardless of how they originally entered that post, the option to choose either the degree or diploma quota for further promotion, so long as they hold the relevant qualification. It reasoned that the opposite reading, adopted by the High Court, would lead to the absurd result of a more qualified (degree-holding) officer being permanently outranked by a less qualified junior who later acquired a degree, which the law could not have intended.

Lesson Learnt

Service and promotion rules should be interpreted to avoid absurd or unfair outcomes, and an employee who has genuinely earned a higher qualification is ordinarily entitled to exercise the promotion option meant for that qualification, even if they entered the relevant post through a different route.

Official source (sci.gov.in)View Judgment (PDF)

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